To support its policy and raise the bar for the protection of human rights across its value chain, VINCI actively participates in various collaborative initiatives, including Building Responsibly, a global business initiative co-founded by the Group that serves the engineering and construction industry, Entreprises pour les Droits de l’Homme (EDH, Businesses for Human Rights), Business for Inclusive Growth (B4IG), and the Leadership Group for Responsible Recruitment. These collaborative initiatives and tools are described in more detail in paragraph 4.3, “Duty of vigilance with regard to human rights”, of the Group’s duty of vigilance plan, pages 269 to 279.
VINCI’s commitment to human rights is reflected in specific actions that are closely aligned with its operations and tailored to the level of risk. In Qatar for instance, where VINCI is present through Qatari Diar VINCI Construction (QDVC), employment and working conditions have been monitored more closely, particularly for employees of temporary employment agencies and subcontractors. Further details on the actions taken can be found in paragraph 4.3, “Duty of vigilance with regard to human rights”, of the Group’s duty of vigilance plan, pages 269 to 279. In addition, the Group’s website includes a page devoted to VINCI in Qatar: www.vinci.com/vinci.nsf/en/item/qatar-en.htm.
Tools developed by VINCI to “protect, respect and remedy” (*) the potential human rights impacts relating to its activities
(*) “Guiding Principles on Business and Human Rights: Implementing the United Nations ‘Protect, Respect and Remedy’ Framework”: https://bit.ly/3KB625L.
Integrated, cross-business approach, managed at the highest level within the Group
Ethics the second commitment from the VINCI Manifesto is central to all professional relationships between VINCI and its stakeholders. This commitment, led at the highest level, is integrated across all the Group’s business lines using a cross-business approach. VINCI has embraced a global acculturation approach engaging everyone to adopt collective and individual behaviours that are aligned with this commitment.
Two reference guides constitute the framework for VINCI’s recommendations and requirements in this area:
These two documents are available in 31 languages on the Group’s website and intranet, and are included in the onboarding pack for new employees. VINCI’s managers are formally committed to respecting them and ensuring that they are applied.
Under the delegations of authority granted to them in relation to the general guidelines, operational managers are responsible for ensuring that appropriate measures are put in place for their business to prevent and detect acts of corruption.
Structured governance framework
Working closely with all the Group’s functions, the Ethics and Vigilance Department supports the implementation of the Group’s compliance arrangements and specifically its antitrust and corruption prevention procedures.
The Ethics and Vigilance Committee has seven members, five of whom also serve on the Executive Committee. It ensures that the compliance procedures covered by the Code of Ethics and Conduct are implemented and amended as necessary, particularly with regard to:
It oversees changes to the Code of Ethics and Conduct and the Anti-corruption Code of Conduct, and met five times in 2023.
The network of ethics directors, coordinators and officers, made up primarily of general counsels and ethics directors, oversees the implementation of business ethics arrangements and monitors progress with relevant action plans in the business lines.
The Ethics and Compliance Club, which is led by the Group Ethics and Vigilance Department and brings together the Group’s General Counsel and the main compliance officers and managers from each business line as well as the Chief Audit Officer, monitors emerging regulatory developments and shares best practices relating to business ethics and the duty of vigilance. This club helps prevent unethical business practices. It met four times in 2023.
In addition, the Data Privacy Committee (previously the GDPR Representatives Club), which is made up of representatives appointed by each of the Group’s business lines, provides support for the deployment and development of effective personal data protection processes, notably in accordance with Regulation (EU) 2016/679, known as the General Data Protection Regulation (GDPR). Coordinated by the Ethics and Vigilance Department, this club supports the sharing of tools and best practices, liaising closely with the Chief Information Security Officer (CISO). The Data Privacy Committee, which met three times in 2023, is supported by a network of correspondents in the business lines.
